On February 26, 2025, the Listing and Surveillance Committee of Nasdaq Tallinn decided to impose a fine in the amount of five thousand (5000) euros to Punktid Technologies AS for violation of Nasdaq Tallinn rules and regulations chapter First North Rules (hereinafter FNR) clauses 1.1, 3.2, 3.4, 3.6, 3.7, 20.1, 23.3, 26.2.1, 26.2.2 and 27.2.

Background:

According to FNR clauses 1.1, 3.2, and 3.6, the Issuer admitted to trading on First North market is subject to FNR Rules and to requirements of other legal acts throughout the trading period, including the legal acts that regulate the public offers and disclosure of information. The Advisors must also comply with the requirements set out in the Rules in accordance with clause 20.1.

According to FNR clause 3.4, the economic, legal or other activities or situations of the Issuer shall not jeopardize the interests or fair and equal treatment of investors.

According to FNR point 3.7, the Issuer shall pay the fees to the Exchange as set forth in the price list (service fees).

Under FNR point 23.3, any other information that is, among other things, required by the Rules is subject to disclosure. According to FNR point 27.2, the Issuer shall immediately disclose all circumstances and events that materially affect or could affect the Issuer’s business or financial standing.

According to FNR points 26.2.1 and 26.2.2, the Issuer must prepare an audited annual financial report and submit it to the Exchange under the conditions and in the manner stipulated in the laws of the Issuer's home state. The Issuer is obligated to submit to the Exchange, along with the annual financial statement, also the auditor's opinion.

Circumstances:

Punktid Technologies AS has not fulfilled its obligation to disclose information according to the Rules or other requirements of the Rules, which oblige the Issuer to timely submit an audited annual financial report along with the auditor's opinion, pay service fees stipulated in the price list, and prohibit jeopardizing the principles of fair and equal treatment of investors and the protection of their interests.

Accordingly, Punktid Technologies AS has repeatedly violated the requirements of the First North Rules.

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Nasdaq Baltic is a common name for exchanges, regulated markets, alternative markets First North operated by Nasdaq companies in the Baltic states, i.e. Nasdaq Tallinn AS, Nasdaq Riga AS and AB Nasdaq Vilnius.